Warm Homes privacy notice
This notice explains what personal data (information) we hold about you, how we collect, how we use and may share information about you. We are required to give you this information under data protection law.
Who we are
The Warm Homes scheme is a partnership between Kent County Council (KCC), local district councils, and wider agencies, to support residents of Kent and Medway to save energy in their home.
KCC collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws. Our Data Protection Officer is Benjamin Watts.
Personal information we collect and use
Information collected by us
In the course of grant eligibility enquiries we collect the following personal information about you, and others living at your address, when you provide it to us:
- contact details (for example, postal address, telephone number, email address)
- benefits information
- health information
- income information
- date of birth.
If you have proceeded to have an installation through the Warm Homes programme, we may ask for your feedback on the service and for the following equalities information from you:
- gender identity
- disability or impairment
- religion or beliefs
- sexual orientation.
Some of this personal information we collect from you is more sensitive and is also known as ‘special category’ data, which requires a higher level of protection. Under GDPR, special category data means data in relation to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, sexual orientation, sex life, and health data.
KCC asks for equalities information from you to help ensure equality of opportunity or treatment, however, you are under no obligation to provide this to KCC.
How we use your personal information
Your information is used to:
- inform your local district council, to assist with your referral, where needed, and to determine if you are eligible for funding (where applicable)
- analyse the data within each district to evaluate the success of the scheme across geographical areas. This data may be analysed by KCC or your local district council, and may be shared with wider partners in an aggregated and anonymised format.
- analyse trends in equalities data to understand who is accessing our service and ensure that everyone is treated fairly and equally, and that no one gets left out. We won't share the information you give us with anyone else. We'll use it only to help us make decision and improve our services. Your personal data will be anonymised when this analysis is carried out.
How long your personal data will be kept
We will hold your personal information for up to a maximum of 6 years, after which time it will be securely destroyed.
Reasons we can collect and use your personal information
We rely on your consent under article 6(1)(a) GDPR as the lawful basis to process your personal data. We also rely on your explicit consent under article 9(2)(a) GDPR as the lawful basis to process your special category data .
As mentioned above you are not obliged to provide us with equalities information, however, if you do choose to provide this to us, we rely on your consent as the lawful basis to process this information. Most of the equalities information about you will be special category data and so we also rely on your explicit consent as the lawful basis to process this data.
You have the right to withdraw consent at any time by emailing firstname.lastname@example.org.
Who we share your personal information with
We routinely share your:
- contact details
- date of birth
- benefits information
- income information
We share this information with our warm homes contractor and your local district council, to assist with your referral where needed, and to determine if you are eligible for funding (where applicable).
If you have contacted us via our Warm Homes Call Centre, the information you provide is processed by our Call Centre operator (Shepway Lifeline) who share this information with us to assist your referral.
We will share personal information with law enforcement or other authorities if required by applicable law.
Under GDPR you have rights which you can exercise free of charge which allow you to:
- know what we are doing with your information and why we are doing it
- ask to see what information we hold about you (this is known as a 'subject access request')
- ask us to correct any mistakes in the information we hold about you
- object to direct marketing
- make a complaint to the Information Commissioner's Office
- withdraw consent at any time (if applicable)
Depending on our reason for using your information you may also be entitled to:
- ask us to delete information we hold about you
- have your information transferred electronically to yourself or to another organisation
- object to decisions being made that significantly affect you
- object to how we are using your information
- stop us using your information in certain ways
We will always seek to comply with your request however we may be required to hold or use your information to comply with legal duties. Please note, your request may delay or prevent us delivering a service to you.
For further information about your rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office on individuals’ rights under GDPR.
If you would like to exercise a right, please contact the Information Resilience and Transparency Team at email@example.com.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Who to contact
Please contact the Information Resilience and Transparency Team at firstname.lastname@example.org to exercise any of your rights, or if you have a complaint about why your information has been collected, how it has been used or how long we have kept it for.
You can contact our Data Protection Officer, Benjamin Watts, at email@example.com, or write to: Data Protection Officer, Sessions House, Maidstone, Kent ME14 1XQ.
GDPR also gives you a right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted on 03031 231113.
Read our corporate privacy statement.